Before a Single Page Is Read: The FOI Cost Estimates That End Requests at the Door

The refusal often arrives before the search begins. A requester asks for emails, contracts or internal assessments; the public body replies that answering would exceed the 'appropriate limit' under the Freedom of Information Act. No documents are released. No pages are reviewed. The request ends at a costing exercise.

The Ferret reviewed 142 refusal notices issued between January and September 2026 by 78 UK public bodies, including local authorities, central government departments, arms-length bodies, police forces and NHS trusts. The sample is not a complete census, but it offers a snapshot of how the cost limit is being used at the point where scrutiny is meant to start.

The arithmetic of saying no

Under the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004, most public authorities can refuse a request if the estimated cost of locating, retrieving and extracting information would exceed £450, calculated at £25 per hour for 18 hours. Central government departments have a £600 limit, equivalent to 24 hours. The limit is not a cap on the value of transparency. It is a resource threshold, and it can be a legitimate one: some requests are genuinely sprawling, poorly defined or impossible to answer without disproportionate work.

But the notices reviewed by The Ferret suggest that the threshold is often doing more work than the request itself. The most common specific figure in the sample was £450, appearing in 31 notices. A further 18 quoted £600. Among estimates said to exceed the limit, £475, £500 and £540 recurred. In 37 notices, the authority did not give a specific figure at all, saying only that the cost would 'exceed the appropriate limit'.

That matters because the Freedom of Information Act requires a reasonable estimate, not a rhetorical one. The Information Commissioner's Office guidance says authorities should be able to explain how they arrived at the figure, including the tasks involved and the time each would take. In many of the notices reviewed, that explanation was thin. A typical response listed 'locating, retrieving and reviewing' as the activities concerned, without saying how many records, systems or staff were involved.

What the notices say

One district council in the south-west refused a request for correspondence about a leisure centre redevelopment, estimating the cost at £475. The notice said the request would require 'officer time across several departments'. It did not identify the departments, the number of emails or the search terms used. A central government body refused a request for minutes of meetings with a trade association, quoting the £600 limit and saying that relevant material was 'likely to be held across multiple teams'. It did not say which teams.

Such wording is not unusual. In 44 notices, the authority used a version of the phrase 'locating, retrieving and extracting' without further detail. In 12, the estimate appeared to be based on the requester's own wording rather than a documented search. Several notices mixed the cost limit with other exemptions, leaving the requester uncertain whether the request had been refused because of cost, confidentiality or both.

The pattern is not evenly spread. Some authorities provided a breakdown of hours, systems and staff grades. Some invited the requester to narrow the scope, which is good practice. Others treated the cost limit as a closing door. One requester who asked for the number of complaints about a waste contract was told that the request would exceed £450, even though the authority's own website published complaint figures by category. The refusal did not explain why the published data could not be used.

A reasonable estimate or a convenient shield?

The cost limit is not a secrecy exemption. It does not say that information is withheld because disclosure would be harmful. It says that finding it would take too long. That makes the quality of the estimate central. If the estimate is robust, the refusal is defensible. If it is a round number attached to a vague description, it becomes a shield.

The Ferret found evidence of both. In eight cases, authorities revised their estimates after the requester asked for a breakdown. In three, they released some information after narrowing the scope. That suggests the initial refusal was not always the final word. But most requesters do not appeal, and the notices themselves do not invite scrutiny of the arithmetic.

There is also a chilling effect that is harder to measure. Requests about budgets, contracts and decision-making are often the ones most likely to trigger cost estimates, because the material is spread across finance, legal and service teams. A requester who is told that scrutiny will cost £500 may simply stop. The public record then contains no refusal that looks like censorship, only a routine administrative reply.

What scrutiny loses

The cost limit was designed to protect public authorities from disproportionate burden. It was not designed to allow a request to be dismissed before anyone has looked. The difference between those two purposes lies in the paperwork: a reasoned estimate, a clear explanation and a genuine offer to help narrow the request.

The notices reviewed by The Ferret show that this difference is not always observed. The £450 and £600 figures appear so often that they risk becoming a reflex rather than a calculation. When that happens, the limit stops being a resource cap and starts being a door that closes before the public can see what is behind it.